Wednesday, October 5, 2016

In response to a Freedom of Information Act request filed by
the Alliance for Green Heat, Hearth & Home Technologies (HHT) and Ravelli
released actual efficiency numbers for several of their popular pellet stove models. Efficiencies ranged from 56% to 76%.

Wood and pellet stoves certified after May 2015 must test
for and disclose their efficiency to consumers, as required by new EPA
regulations. Prior to these regulations, stove manufacturers claimed that any
available efficiency data was confidential and they generally did not provide
it to consumers.However, many companies
provided the efficiency data to the EPA as part of the certification
process.

The Alliance for Green Heat, based on its legal counsel,
argued that the EPA could not keep efficiency data it collected prior to May
2015 confidential because it was based on emission data, and emissions data
cannot be confidential.In July 2015 the
EPA declined to release the efficiencies to the Alliance, in keeping with
its longstanding practice that they would keep all data confidential if
it was submitted as Confidential Business Information (CBI).

Originally, the Alliance had asked for the weighted average efficiency
as well as the efficiency from each of the four burn rates that labs use to
test stoves.The Alliance agreed to drop
the request for the individual burn rate efficiencies and only request the
average.Based on that change, HHT and
Ravelli agreed to allow the EPA to release their efficiency numbers to the
Alliance with some conditions.

The EPA provided a final response with a data
sheet (pdf) attached.The efficiency
numbers (HHV based on B415.1) from that data sheet are:

CompanyModelEfficiency

HHTAccentra
52i insert76%

HHT Mt
Vernon E275%

HHTMt
Vernon AE71%

RavelliRV10070%

RavelliRV8056%

The Alliance requested efficiency information for these
particular models, along with several others, because we were in the process of
independently testing a selection of pellet stoves.The Alliance was also attempting to convince
the EPA to change their policy and disclose all efficiency data, even if that
efficiency data had been marked as Confidential Business Information.The Alliance argued

The Ravelli RV80 Ceramica
is far cleaner than the original
RV80. The new, improved
efficiency is not yet posted on
the EPA list.

that efficiency was of
such basic importance to consumers and that keeping it confidential served no
useful purpose. That attempt was unsuccessful. The Alliance is not appealing.

The five newly released actual efficiency numbers are not
included on the EPA’s list
of certified stoves, where about 25% of the stoves have actual efficiencies
listed. Except for one of the Ravelli’s,
these five stoves all have around average or above average efficiencies.The Ravelli RV80 was only 56% efficient, but Ravelli has a updated version of this stove, the RV80 Ceramica, that has much lower grams per hour. (In response to this post, the EPA found that they had mistakenly omitted posting the efficiency of the RV80 Ceramica and said they would post it soon.)Virtually all stoves claim
to be 75% efficient to be eligible for the $300 federal tax credit, and EPA
listing or disclosure that reveals the stove is not even 60% efficient does not
appear to deter manufacturers from continuing to claim eligibility for the tax
credit.

Note: A representative of Ravelli replied to this blog saying that the RV80 is now out of production. The Ravelli representative said that the updated RV80 Ceramica has an efficiency "over 75%." We asked Ravelli to support the "over 75%" figure with a lab report. EPA regulations require companies to post lab report on their website for any stove tested under the 2015 NSPS. Some companies comply, and others resist this level of transparency.